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Privacy Policy

UBM Applicant Privacy Notice

UBM has prepared this Applicant Privacy Notice ("Notice") for applicants to roles with UBM.  UBM for this purpose is the Company to whom you are applying for a role and will be one of the following: UBM Shared Services Ltd, UBMG Ltd, UBM Property Services Ltd, UBM (UK) Ltd, OES Exhibitions Ltd (Allworld), AMA Research Ltd, UBMi B.V. (Amsterdam), UBM Canon Deutschland GmbH (Germany), Canon Communication France (France).

In connection with your application we have to process your personal data. We know that the fact that we'll need to use your personal data may be quite obvious to you. However, the purpose of this Notice is to give you information about how UBM collects, processes, stores and otherwise uses information about you, and your rights in relation to that information.

UBM needs to process your personal data in order to process your application for employment.  There are also statutory requirements we have to comply with in relation to your application.  If we are not able to carry out the processing activities we describe in this Notice we may not be able to continue with your application.  Of course, we hope it would never come to that, and this is simply information we are obliged to provide to you as part of this Notice. 

We need to ask for your specific consent to process your personal data in a particular way in certain circumstances, such as for the purpose of conducting background checks prior to you commencing employment with us, to enable relevant third parties to release information about you as part of those checks.  Please sign and complete the consent form at the end of this Notice to confirm you consent to us processing your data for the purposes of carrying out the background checks listed.  

Although we are seeking your consent in relation to certain background checks, you should note that in most cases we will process your personal data for the reasons set out in this Notice and it won't be appropriate or necessary for you to provide consent as the legal basis for processing your personal data. 

When we say "UBM", "we" or "us" in this document, we mean the UBM entity that you're applying to work for. In addition, you will see a number of references to the "UBM Group", which includes all other UBM entities globally.  (Details of these can be obtained from the Company Secretarial Department.    We may update this document from time to time, for example if we implement new systems or processes that involve the use of personal data.

In this Notice you will see reference to "GDPR" - that refers to the European Union General Data Protection Regulation which is a European law governing your rights in relation to your personal data, and how organisations should protect it.

Index
To help you find information quickly on any particular question you might have, we have set out an index below. Just click on the question you would like answered and you will be taken to the relevant section:

What categories of personal data does UBMcollect about me and why does UBM use it?
Why does UBM need to collect, process and use my Applicant Data and Sensitive Applicant Data?
Got it - but who might UBM share my personal information with?
How long will UBM keep my personal information for?
What rights do I have in respect of my personal information?
Who can I contact about this stuff?

What categories of personal data does UBM collect about me and why does UBM use it?


"Personal data" means any information relating to you. UBM will collect, process and use the following categories and types of personal data about you:

identification data, such as your name, citizenship, passport data, photo, drivers' licence information, national insurance number, health insurance and governmental retirement plan information and tax reference;
personal information, such as your date and place of birth, emergency contact details, gender, immigration status and history;
contact details, such as your home address, telephone number and email address;
education and work experience, such as contact details for your current/former employer, information about your educational background, your work experience and other experience;
other application data, such as the information included in your application form/CV;
information collected as part of the interview process, such as notes taken from your interview or information provided from recruitment agencies;
background check information, such as information obtained through reference checks and confirmation about your work/educational background. 
together "Applicant Data".

We collect and use this Applicant Data for a variety of reasons linked to processing your application for a role with us. To help clarify these we have set out below a list of reasons why we collect and use this data (the "Processing Purposes") along with examples of some of the Applicant Data used for each of the Processing Purposes:

administering and processing your application, (including processing a job offer should you be successful) including identification data, contact details, information about your qualifications and employment history, and information obtained during your interview and information contained in your CV;
to determine your eligibility for the role you applied for, including identification data, contact details, information about your work and education experience, information obtained during your interview and information contained in your CV;
conducting background checks as part of your application, including identification data, contact details, information about your qualification and employment history;
complying with applicable laws and employment-related requirements along with the administration of those requirements, such as income tax, national insurance deductions, and employment and immigration laws which involves the processing of identification data and contact details;
monitoring and ensuring compliance with applicable policies and procedures and laws, which involves the processing of your identification data and contact details, including the operation of a whistleblowing hotline;
communicating with you, UBM employees and third parties, including informing you of future opportunities with UBM (such as existing or potential business partners, suppliers, customers, end-customers or government officials), which involves the processing of identification data and your contact details;
responding to and complying with requests and legal demands from regulators or other authorities in or outside of your home country which involves the processing of identification data and contact details;
complying with corporate financial responsibilities, including audit requirements (both internal and external) and cost/budgeting analysis and control which involves the processing of identification data, contact details, information about the role you have applied for, including the role's salary and benefits.
In addition to the collection, processing and use of the Applicant Data, UBM collects, processes and uses the following special categories of personal information about you which we describe as "Sensitive Applicant Data":

health and medical data, such as information on disability for purposes of accommodating your application and interview and compliance with legal obligations;
criminal records data, in the event that UBM has conducted or received the results of criminal records background checks in relation to you in the process of your application, where relevant and appropriate to the role that you are applying for;
race or ethnicity data such as information contained in your passport or other citizenship and right to work documentation, and information which you have voluntarily provided to UBM for the purposes of our equal opportunities and diversity monitoring and initiatives;
sexual orientation data where this has been provided voluntarily to UBM for the purposes of our equal opportunities and diversity monitoring and initiatives;
data about your political opinions, religious or philosophical beliefs where you have provided this data voluntarily as part of your application or in response to equal opportunities and diversity monitoring initiatives.

Why does UBM need to collect, process and use my Applicant Data and Sensitive Applicant Data?


Both the Applicant Data and Sensitive Applicant Data are needed by UBM to carry out a variety of activities that are linked to your application for a role with us and UBM's compliance with its obligations as part of the recruitment process and as a business.
We are required to explain to you the legal bases for our collecting, processing and use of your Applicant Data and Sensitive Applicant Data. We have a number of these, so please bear with us, and to make sure you have the full picture we have listed them all below:

For Applicant Data, our legal bases are:

compliance with legal obligations, in particular in the area of labour and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws; the legitimate interests of UBM, UBM affiliates or other third parties (such as existing or potential business partners, suppliers, customers, end-customers or governmental bodies or courts); your consent, where that is appropriate, meets the requirements of data protection law and has been separately obtained; protection of vital interests of you or of another individual; performance of a task carried out in the public interest or in the exercise of official authority vested in UBM.

For Sensitive Applicant Data, our legal bases are:

to carry out the obligations and to exercise the specific rights of UBM or you in the field of employment and social security and social protection law as permitted by local data protection law and/or a collective agreement; to protect the vital interests of you or of another individual where you are physically or legally incapable of giving consent; public data as made public manifestly by you; to establish, exercise or defend a legal claims or whenever courts are acting in their judicial capacity; for substantial public interest as permitted by local data protection law; for assessment of the working capacity of the employee as permitted by local data protection law; explicit consent as allowed by local data protection law (and where you have voluntarily provided Sensitive Applicant Data without being asked to do so).

We appreciate that there is a lot of information there, and we want to be as clear with you as possible over what this means. Where we talk about legitimate interests of UBM or third parties, this can include:

Assessing your suitability for employment/engagement with UBM;
Implementation and operation of a group-wide organisational structure and group-wide information sharing;
Right to freedom of expression or information, including in the media and the arts;
Prevention of fraud, misuse of company IT systems, or money laundering;
Operation of a whistleblowing scheme;
Physical security, IT and network security;
Internal Investigations;
Proposed mergers and acquisitions.

When relying on the legitimate interests basis for processing your personal data, we will balance the legitimate interest pursued by us and any relevant third party with your interest and fundamental rights and freedoms in relation to the protection of your personal data to ensure it is appropriate for us to rely on legitimate interests and to identify any additional steps we need to take to achieve the right balance.

Got it - but who might UBM share my personal information with?


As you may know, we are part of the global UBM Group, and several entities in this group are involved in the Processing Purposes. To ensure that the Processing Purposes can be completed, your information may be shared with any of the entities within the UBM Group network as well as third party Data Processors such as Recruitment Agencies and IT Systems Support and Maintenance providers. Where we do share data in this way, however, it is our policy to limit the categories of individual who have access to that personal information.

UBM may transfer personal data to third parties, including to entities within and outside the UBM Group located in any jurisdictions where UBM Group entities are located, for the Processing Purposes as follows:

Within the UBM Group.  As the UBM entity that you are applying to is part of a wider group headquartered in the UK with offices located across the globe, which partially share management, human resources, legal, compliance, finance and audit responsibility, UBM may transfer the Applicant Data and Sensitive Applicant Data to, or otherwise allow access to such data by other entities within the UBM Group, which may use, transfer, and process the data for the following purposes: to maintain and improve effective administration of the workforce;  to communicate information about the UBM Group; to maintain a corporate directory; to maintain IT systems; to monitor and assure compliance with applicable policies and procedures, and applicable laws; and to respond to requests and legal demands from regulators and other authorities.
Regulators, authorities, and other third parties.  As necessary for the Processing Purposes described above, personal information may be transferred to regulators, courts, and other authorities (e.g., tax and law enforcement authorities), independent external advisors (e.g., auditors), insurance providers, pensions and benefits providers, internal compliance and investigation teams (including external advisers appointed to conduct internal investigations).
Data processors.  As necessary for the Processing Purposes described above, personal data may be shared with one or more third parties, whether affiliated or unaffiliated, to process personal information under appropriate instructions ("Data Processors"). The Data Processors may carry out instructions related to recruitment, workforce administration, IT system support and maintenance, payroll and compensation, training, compliance, and other activities, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal information, and to process the personal information only as instructed.

For a full list of the UBM Group entities and third parties that we may share your data with, please contact us as set out below.
As you may expect, some of the recipients we may share Applicant Data and Sensitive Applicant Data with may be located in countries outside of Europe. In some cases, this may include countries located outside the European Union and/or European Economic Area ("EAA"), and in particular this will include countries throughout Asia and the Americas where the UBM Group operates.

Some countries where recipients may be located already provide an adequate level of protection for this data (e.g. Canada), and transfers to other countries such as the USA may be protected under arrangements such as the EU-US Privacy Shield. Nonetheless, for transfers to UBM Group entities outside of the EEA, UBM will be bound by the EU Standard Contractual Clauses pursuant to Article 46(2)(c) GDPR, which the European Commission has assessed as providing an adequate level of protection for personal data, to ensure that your data is protected adequately.

If recipients are located in other countries without adequate protections for personal data, UBM will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. This will include using appropriate safeguards such as the EU Standard Data Protection Clauses. You can ask for a copy of  such appropriate safeguards by contacting us as set out below ("Who can I contact about this stuff?").

How long will UBM keep my personal information for?

It is our policy not to keep personal information for longer than is necessary.  We may, for example, keep your personal information for a reasonable time after your application process is completed, in case we have future job opportunities that we consider you are suitable for. Where personal information is kept, that period will be determined based on the applicable local law. For further information, please refer to the UBM Data Retention Policy or contact us as set out below to request further details on how long UBM will retain different categories of personal information.

What rights do I have in respect of my personal information?

You have a number of rights in relation to your Applicant Data and Sensitive Applicant Data.  These can differ by country, but can be summarised in broad terms as follows:

(i)         Right of access 
You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.
(ii)        Right to rectification 
You may have the right to rectify inaccurate or incomplete personal data concerning you. We encourage you to review this information regularly to ensure that it is accurate and up to date.  
(iii)       Right to erasure (right to be forgotten)
You may have the right to ask us to erase personal data concerning you.
(iv)       Right to restriction of processing
In limited circumstances, you may have the right to request that we restrict processing of your personal data, however where we process Applicant Data and Sensitive Applicant Data for the Processing Purposes we think that we have a legitimate interest in processing which may override a request that you make.
(v)        Right to data portability
You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
(vi)       Right to object and rights relating to automated decision-making 
Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.
To exercise any of these rights, please contact us as stated under below (Who can I contact about this stuff?). 
You also have the right to lodge a complaint with the competent data protection supervisory authority, which in the UK is the Information Commissioner's Office (the 'ICO').

Who can I contact about this stuff?


If you have concerns or questions regarding this Notice or if you would like to exercise your rights as a data subject, you can get hold of the right person here: 
Data Protection Office, UBM Company Secretarial Department, 240 Blackfriars, London, SE1 8BF and dpo@ubm.com

Processing Your Personal Data - The Headlines
What categories of personal data does UBM collect about me and why?

“UBM” for this purpose means the employing entity to which you are applying for a role which will be one of the following: UBM Shared Services Ltd, UBMG Ltd, UBM Property Services Ltd, UBM (UK) Ltd, OES Exhibitions Ltd (Allworld), AMA Research Ltd, UBMi B.V. (Amsterdam), UBM Canon Deutschland GmbH (Germany), Canon Communication France (France) and any other EMEA or UK employing entity.

"Personal data" means any information relating to you.  During the application process, UBM will collect, process and use your personal data, for a range of different purposes.  For example:

What personal data?

Identification - your name, nationality, national insurance number, bank details, passport
Contact details
Education and work experience
Organisational data
Information collected as part of your interview process
Background check information
Other application data (e.g. information contained in your CV and obtained from recruiters)

Why?

To process your application
To determine your eligibility for the role you have applied for
To conduct background checks as part of your application
To communicate with you about future job opportunities
To comply with the law and our obligations
To communicate with you and with UBM employees and third parties
To comply with our financial and regulatory obligations

It's important to know that UBM may also need to process sensitive personal data about you such as health and medical data, criminal records data, race or ethnicity data and sexual orientation data.
Find out more about what data UBM processes and why by reading the detailed Applicant Privacy Notice, a copy of which can be found [here].
Who might UBM share my personal data with, and what happens if it's transferred out of the UK?

As you know, we are part of the global UBM plc group - and entities across the UBM network are involved in processing data. We might also need to transfer your data to other third parties - e.g. potential business partners, acquiring entities, suppliers, customers, or government bodies. Our policy is to limit who has access to that data as much as we can. If we need to transfer data out of the UK, UBM  will take all necessary measures to ensure your data is adequately protected. Find out more about who your data is shared with, and what steps we take to protect it [here].
How long will UBM keep my personal data for? 
We won't keep it for any longer than we need to, either to comply with the law or to ensure that we are complying with our obligations to you and other third parties.  Find out more [here]. 
What rights do I have in respect of my personal data?
You have a number of rights in relation to your data. These include a right to access, correct and erase your data as well as more technical rights to restrict the way we process it, and to transfer your data.
Your rights are important, and we've set them out in detail [here]. 
Who can I contact if I have questions?
If you have concerns or questions regarding your personal data, Data Protection Office on dpo@ubm.com.